Legal and Privacy

Introduction

This material and all other material on www.fasanara.com or on any of its associated social media pages (each a “Material” and together the “Materials”) is owned by Fasanara Capital Ltd (“Fasanara”), an asset manager which is regulated by the Financial Conduct Authority of the United Kingdom (“FCA”), with the FCA registration number 551020, and whose registered address is 4th Floor, 40 New Bond Street, London, United Kingdom, W1S 2RX. Please read this disclaimer (the “Disclaimer”) before accessing and viewing any of the Materials, as it explains certain restrictions imposed by law on the distribution of the information contained in the Materials.

By accessing and viewing any Material you confirm that:

• the terms and conditions herein will apply to you each time you access the Material, and each access will be subject to the disclaimers, risk warnings and other information set out herein;

• you are a professional investor or eligible counterparty as defined by MiFID; and

• you are allowed to access and view the Material in accordance with all applicable laws and regulations of your country of residence.

Accuracy of information

Whilst considerable care has been taken to ensure the information contained within the Materials is accurate and up to date, no warranty, guarantee or representation is given as to the accuracy, reliability or completeness of any information and no liability is accepted for any errors or omissions in such information. The information included in the Materials has been produced by Fasanara and its affiliates, as appropriate (“Fasanara Group”). Any reproduction, disclosure or dissemination of the Materials by you is prohibited.

Some of the information in the Materials may contain projections or other forward-looking statements regarding future events or future financial performance of countries, markets or companies. These statements are only predictions, opinions or estimates made on a general basis and actual events or results may differ materially. No information in the Materials constitutes investment, tax, legal or any other advice.

All investment strategies, products and services referred to in the Materials is subject to change without notice. Fasanara Group may amend the Materials (including this Disclaimer) and its investment strategies, products and services at any time with or would notice to the user. Fasanara Group is under no obligation to update any Materials or to correct inaccuracies which may become apparent. Fasanara Group shall have no liability for any direct, indirect, consequential or special losses or damages of any kind whatsoever arising from or in connection with any use of the Materials or its contents.

No information, whether oral or written, obtained by you through or from any Materials or from any conversation with Fasanara Group staff or a professional consultant will have the effect of varying this Disclaimer.

Not an offer

Each Material (and the information contained therein) is provided for information purposes only, and does not constitute either an offer, invitation, inducement or a solicitation to buy or sell any securities or investment products nor is it a recommendation for any security or investment product. Accessing and viewing the Materials (and the information contained therein) may not be lawful in certain jurisdictions. In some jurisdictions, only certain categories of person and/or entities who would make certain specific enquiry actions by their own initiative (“reverse solicitation”, “reverse enquiry”, “private placement non solicitation” or other similar regulation) may be allowed to access the Materials. The information contained in the Materials is not directed at or intended for distribution to, or use by, any person in any jurisdiction or country where such use or distribution would be contrary to any applicable local law or regulation or would subject Fasanara Group to any registration or licensing requirement in such jurisdiction. Accordingly, unless an exemption under the relevant securities law is applicable, and/or in case that you would ask for access to any Materials (and/or the information contained therein) to Fasanara Group from your own initiative only (by means of “reverse solicitation”, “reverse enquiry”, “private placement non solicitation” or other similar regulation), any such securities or investment products referenced in any Materials may not be offered, sold, resold, taken up, exercised, renounced, transferred or delivered, directly or indirectly, in or into any jurisdiction if to do so would constitute a violation of the relevant laws of, or require registration thereof in, such jurisdiction. It is your responsibility to inform yourself of any applicable legal and regulatory restrictions and to ensure that your access and use of this information does not contravene any such restrictions and to observe all applicable laws and regulations of any relevant jurisdiction. Professional advice should be sought in cases of doubt, as any failure to do so may constitute a breach of the securities laws in any such jurisdiction.

The funds referred to herein are offered, as part of a formal process, by their current offering materials only. Potential investors should be aware that a Material may not provide all the information which is necessary or desirable to make such a decision and should undertake their own due diligence. The information memorandums and key investor information documents contain more complete information about these funds and should be read carefully in conjunction with the latest annual reports before investing. Depending on the countries where the funds are offered, the information memorandums are supplemented by an addendum containing supplementary information required by the regulations of such jurisdictions.

Investors should be aware that protections provided by relevant local laws and regulations may not apply to investment in the funds referred to herein. It is your responsibility to be aware of the applicable laws and regulations of your country of residence. In particular, UK investors should note that holdings or investments in the funds will not be covered under UK Financial Services Compensation Scheme. Investors will have no right of cancellation under FCA’s Cancellation and Withdrawal rules.

The funds referred to herein are not registered under the United States Investment Company Act of 1940 and securities issued by the funds are not registered under the United States Securities Act of 1933. This is not an offer to sell, nor a solicitation of an offer to buy, the securities of any fund in the United States, its territories, possessions, or protectorates under its jurisdiction nor to nationals, citizens or residents in any one of those areas.

Fasanara Group will not regard any person who accesses and views a Material as its client in relation to any of the investment products or services detailed in a Material. Fasanara Group will not be undertaking arranging activities at any time on behalf of the individuals electing to access and view a Material.

No investment advice

The Materials are provided for information purposes only. Nothing in a Material will constitute legal, tax or investment advice or recommendations. The investment products described may not be available to, or suitable for, all investors. In addition, current levels, bases and reliefs from tax depend on individual circumstances, which may also change in the future. Investors should not invest in the funds unless they understand its nature and the extent to their exposure to risk. Independent professional advice from a suitable authorised person, including tax advice, should be sought before making an investment decision.

Investment risk

The value of any investment made in the funds or otherwise and the income from such can go down as well as up, and the investor may not get back the full amount invested. Past performance is not a guarantee of future returns. Changes in the rate of exchange may also cause the value of overseas investments to go up or down. Funds that invest in asset classes carrying greater risk may have a higher risk of loss of capital.

Third party websites

Fasanara Group accepts no responsibility for any information contained in any website accessed via a hyperlink from a Material. No other person/company may link their website into any of the Materials without the express written permission of Fasanara. The content, accuracy and opinions expressed in such websites are not checked, analysed, monitored or endorsed by Fasanara Group.

Third party content

Materials and information distributed by Fasanara Group, whether in hard copy, website or electronic format, include general news and information, commentary, interactive tools, quotes, research reports and data concerning the financial markets, securities and other subjects. Some of this content is supplied by third parties (“Third Party Content”) that are not affiliated with Fasanara Group (each a “Third Party Content Provider”). Third Party Content is being provided for non-commercial purposes only and may not be copied, used or distributed without the permission of the relevant Third Party Content Provider. Third Party Content may be protected by international copyrights. All trademarks and service marks appearing in a Material are the exclusive property of their respective owners. These provisions are not intended to, and will not, transfer or grant any rights in or to the Third Party Content, and the relevant Third Party Content Provider reserves all such rights. Fasanara Group’s use of any Third Party Content is not intended to imply that any Third Party Content Provider sponsors, endorses, sells or promotes any Fasanara Group investment strategies, products or services. Third Party Content is provided on an “AS IS” basis and Third Party Content Providers shall have no liability for monetary damages on account of the Third Party Content provided herein.

Enforcement of terms and conditions

These terms and conditions are governed and interpreted pursuant to the laws of England and Wales. If any part of these terms is deemed to be unlawful, void or unenforceable, that part will be deemed severable and will not affect the validity and enforceability of the remaining provisions. None of these terms and conditions are enforceable under the Contracts (Rights of Third Parties) Act 1999 by a person who is not a party to its terms.

Stewardship Code Disclosure

Under Rule 2.2.3R of the Financial Conduct Authority's (“FCA”) Conduct of Business Sourcebook, Fasanara Capital Ltd. (“Fasanara” or “the Firm”) is required to disclose the nature of its commitment to the UK Financial Reporting Council's Stewardship Code (the "Code") or, where it does not commit to the Code, explain its considered choice based on the Firm’s investment approach.

The Code is a voluntary code and comprises a set of twelve ‘apply and explain’ principles for asset managers and asset owners and sets high stewardship standards for those investing money on behalf of UK savers and pensioners, and those that support them.

Fasanara is a supporter of the principles of good stewardship and is committed to working towards compliance with the Code. Our latest Statement on the UK Stewardship Code can be found here.

This statement is subject to annual review and will be updated where necessary to reflect changes in circumstances and actual practice.

SRD Disclosure

Under Rule 2.2B.5.R of the Financial Conduct Authority's ("FCA") Conduct of Business Sourcebook, Fasanara is obligated to disclose whether it maintains an engagement policy concerning the issuers of investments traded on a regulated market or comparable overseas market, referred to as the "Engagement Policy." Alternatively, if Fasanara does not comply with this requirement, it must disclose the reasons behind its decision.

Fasanara acknowledges the objectives that underlie the development of an Engagement Policy and supports them. However, due to the nature of its investment strategy, Fasanara does not engage in formal interactions with investee companies or undertake shareholder engagement activities. Fasanara's exposure to listed issuers on regulated or comparable markets is never undertaken with an activist investor approach. As a result, an Engagement Policy has limited relevance to Fasanara's investment strategy. This statement will be subject to annual review and will be amended as needed to reflect changes in circumstances and actual practices.

Privacy Policy

Our corporate website www.fasanara.com (referred to as the “Site”) is owned by Fasanara Capital Ltd. This privacy policy (the “Privacy Policy”) (together with our separate Internet Browsing and Cookies Policy) discloses our information gathering and dissemination practices. We reserve the right to modify this Privacy Policy at any time.

Fasanara Capital will use your personal data only for the purposes and in the manner set forth in this Privacy Policy which describes the steps taken to ensure our processing of your personal data is in compliance with the General Data Protection Regulation ((EU) 2016/679) ("GDPR") and any implementing legislation ("Data Protection Legislation").

Confidentiality

We will keep your information confidential and only use it within Fasanara, and only transfer it to third parties in the manner described in the below section labelled “Use of third parties”, unless we are under a duty to disclose or share your personal data in order to comply with a court order or other legal or regulatory requirement.

How and why we collect personal data

Through our Site you may have an opportunity to send us information, such as through the "contact us" pages or any other area where you may send e-mails, request information or any query. By choosing to participate in these, you might provide us with some personal information. We may also obtain personal information about you from third parties or through other business activities, such as attending conferences or exchanging business cards. We will in all cases endeavour to ensure you have the opportunity to read this Privacy Policy when processing your personal data.

The personal information we may collect might include your name, address, email address, company details and any other relevant information that may be included within correspondence. In addition, details of your visits to our Site including (but not limited to) IP address, cookies, traffic data, location data, weblogs and other information related to what pages are accessed and when may be collected.

If you are accessing sections of our Site that are password protected or have entered the Site through a link in an email, our Site will identify you as an individual and may collect data including information about the pages you visit, the documents you download or other information to enhance and personalise your future interaction with our Site.

Any information collected about you may be associated with other identifying information we hold. Certain online analytical data may be collected by using cookies in accordance with our Internet Browsing and Cookies Policy.

Fasanara Capital will retain and process your personal data only when this is necessary to achieve our commercial or business objectives and to comply with our regulatory obligations. After careful consideration, Fasanara Capital has concluded the processing of personal data for the reasons mentioned below shall be considered necessary, as there would not be another way of achieving the identified interest of the firm.

Fasanara Capital will always ensure its business interest does not override your rights and freedoms as an individual. We may also retain your information to comply with any applicable laws or regulations. We are legally required to hold some types of information to fulfil our statutory and regulatory obligations. These obligations include regulations made by the Financial Conduct Authority (“FCA”), by whom we are authorised and regulated by in the UK (reference number: 551020 for Fasanara Capital Ltd).

We may, for example, use your information to: respond to queries from you or provide information that you request from us; ensure that content from our Site is presented in the most effective manner for you and for your computer; provide you with information about our products and services; send you promotional materials, newsletters and other communications; provide you with invitations to events, promotions, surveys and market research or other marketing correspondence; respond to your inquiries; verify your information; perform data analysis (such us demographic analysis and consumer research); operate, evaluate and improve our business (developing our products and services, improving our communications, performing auditing or accounting functions); protect against any unlawful activity and prevent fraud; carry out our obligations arising from any contracts entered into between you and us; comply with any legal requirements and our Policies; allow you to participate in interactive features of our service when you choose to do so; notify you about changes to our business, products or services; or any other internal purposes that we believe to be necessary.

As a principle, we will only retain your personal data for such period of time as is necessary to serve our business interest and will not process personal data beyond that point. If you ask for your personal data to be removed, we may still keep it in our records for 5 years to comply with FCA requirements and will proceed to delete it afterwards provided there is no other reason which makes it necessary for us to keep the personal data (e.g. an investigation or pending Court case). You would not be contacted or receive any marketing materials during such period.

Internet browsing, cookies, and analytics

We use cookies to make our site work. Cookies are small text files stored on your device and are used to help with the functionalities of a site or to track and analyse how visitors interact with a site. We will collect cookies in compliance with the PECR and the GDPR. We may collect further cookies to enhance your Site and customer experience. You can always change your approach at any time. By accessing and using our website, you consent to the collection and processing of data as described below.

Some of the cookies we employ are essential and necessary for our site to function, while other cookies allow us to measure and improve the performance of our website. We use Vercel Analytics as a third-party service to help with our website analytics. No personal identifiers that track and cross-check end users' data across different applications or websites, are collected. The recording of data points (i.e. pageviews, custom events) is anonymous. You can learn more about how Vercel Analytics collects and handles data on their privacy page.

You have the option to remove or disable cookies through your browser, please refer to your browser documentation if you feel the need to do so. However, by disabling cookies, certain functionalities of our website may be affected.

How we store, transfer and process personal data

All information you provide to us is stored on secure servers. Information may be transferred, stored and processed by third parties (see below).

Use of third parties

Communicating via the internet and sending information to you by other means necessarily involves your personal information passing through or being handled by third parties, but we do not sell or distribute without your permission your personal information to third parties for purposes of allowing them to market products and services to you.

We have also reviewed all key third party agreements where EU personal data is being processed to ensure they are GDPR compliant and that your rights described herein are being protected.

What safeguards we have in place

Fasanara Capital has security measures in place to protect the loss, misuse and alteration of the information under our control. As no data transmission over the internet can be guaranteed as 100% secure, we cannot ensure or warrant the security of any information you transmit to us and you transfer the data at your own risk. We endeavour to use appropriate security measures, including systems security, backups, business recovery and breach notification procedures, monitoring and testing procedures.

Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Site and accordingly any transmission is at your own risk. However, once we have received your information, we will use all appropriate procedures and security measures to try to prevent unauthorised access to or disclosure of your personal data.

What rights you have with regards to your personal data we process

You have the right to access your personal data and request a copy of the information held by us about you. You also have the right to ask for your information to be transferred to another organisation or to yourself. Where such requests are manifestly unfounded or excessive, we will inform you and we may charge a reasonable fee or refuse to respond to such a request.

You have the right to ask us not to process your personal data for marketing purposes. We will inform you if we intend to use your personal data for such purposes. You can exercise your right to prevent such processing by contacting us directly. You can also exercise the right and change your marketing preferences or restrict any specific uses of your personal data at any time by contacting us.

The accuracy of your information is important to us. We review information we hold to ensure it is up to date and accurate. You have the right to correct any inaccuracies in the details we hold about you – if you change your email address or notice any other information we hold is inaccurate or out of date, please contact us. You have the right to obtain without undue delay the rectification of any inaccurate personal data concerning you.

Your rights to access, rectify, erase or restrict your personal data stated above will be processed by Fasanara Capital usually within 30 days of receiving your request. However, Fasanara Capital may notify you within such timeframe of an increased time period to process your request and its reason. Where Fasanara Capital believes the request is unreasonable it shall notify you and refuse to process your request. Our Site may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites may have their own privacy policies and that we do not accept any responsibility or liability for these policies or the treatment of your personal data by any third parties. Please check these policies before you submit any personal data to these websites.

Complaints

If you believe your personal data has been processed by Fasanara Capital in a way that does not comply with the GDPR, you have the right to lodge a complaint with us directly or with a supervisory authority. If you believe Fasanara Capital did not take action on a request you have sent; or informed you without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy, you have the right to lodge a complaint with a supervisory authority.

Governing law and jurisdiction

This legal notice and all issues regarding our Site are governed by English law and are exclusively subject to the English courts.

Contact information

If you have any questions regarding our Legal & Privacy Policy, you can contact us via email at investors@fasanara.com or in writing to Compliance, Fasanara Capital Ltd, 40 New Bond Street, London, W1S 2RX.